Waterson v Lloyd & Anor [2011] EWHC 3197 (QB) (08 December 2011)
The publications complained of bear the meaning that the claimant was guilty of abuse of Parliamentary rules for his own financial advantage, which is a defamatory statement of fact, not comment or opinion. The defence of honest comment is not available as the publications are statements of fact.
- Citation
- [2011] EWHC 3197 (QB)
- Parties
- Claimant: Nigel Waterson; Defendant: Stephen Lloyd MP; Defendant: Rebecca Carr
- Jurisdiction
- England and Wales
- Judgment Date
- 08 December 2011
- Procedural Posture
- Libel Action / Summary Judgment on Liability
- Outcome
- Judgment for claimant on liability; damages or other relief to be determined later.
- Legal Topics
- Libel, Distinction Between Fact and Comment, Mps' Expenses Scandal, Fair Comment Defence, Election Campaign Publications
Case Brief
Summary, issues, holding and outcome
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Parties
Nigel Waterson
Claimant
Stephen Lloyd MP
Defendant
Rebecca Carr
Defendant
Procedural Posture
Libel Action / Summary Judgment on Liability
Legal Issues
- 1 What is the meaning of the publications complained of?
- 2 Are the publications statements of fact or comment/opinion?
- 3 Are the publications defamatory?
Ratio Decidendi
The publications complained of bear the meaning that the claimant was guilty of abuse of Parliamentary rules for his own financial advantage, which is a defamatory statement of fact, not comment or opinion. The defence of honest comment is not available as the publications are statements of fact.
Court Disposition
Judgment for claimant on liability; damages or other relief to be determined later.
Orders
- Summary judgment entered for claimant on liability.
- Issues as to relief to be determined separately if not agreed.
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